Are you talking about the sample policy on BOL?

Management level policy with underlying procedures O.K., correct? No requirement for Board approval?

I have not yet gotten around to submitting a comprehensive FACT Act policy to the Board at this institution yet due to other more pressing matters. That will come on the heels of getting into compliance by July 1st.

I have the same question about the form referred to in #3.

I assuming they mean a response/follow-up form to the consumers direct dispute, you either say yes or no.

Can you tell me where it states that Chexsystems will be included as a CRA to comply with these changes?

Does anyone have written procedures that they are willing to share? I saw the one on BOL, but I was hoping to get a few more to help me out.

Thanks!

You have to look at the definition of "consumer reporting agency" in the FCRA. ChexSystems meets that definition.

Okay....I have serious tired head from all of the FACTA/FCRA mumbo jumbo. One question for those who still have sanity....

Do you think it would be acceptable to combine red flag, identity theft program, items effective July 1st, etc, etc all into one document for board approval?

I have accumulated way too many policies, programs, etc for this convaluted mess.

I considered that, but then decided against it. That's a lot of information for a board member to have to read.

On our Intranet, I have a section for FCRA. In it I have included separate documents for the policies, procedures and programs named below. I always consider the user. If it's too difficult to find what they are looking for, they end up calling me. By making it easy for them, I hope to preserve some of my precious time!

These are the sections I will have when I am finished:

Accuracy & Integrity Policy
Direct Dispute Procedures
Credit Reporting Agency Dispute Procedures
Reporting Information to Credit Reporting Agencies Procedures

Red Flag Program

and FCRA Procedures that include:

Permissible Uses of Credit Reports
Adverse Action
Alerts/Freezes
Use of Medical Information
Adverse Action

Only the policy and procedures that require board approval are taken to the board.

Can I ask a question? At the end of the day, should we have a policy statement for 1) FCRA/Fact ACt, 2) Reg Flag, 3) ID Theft and 4) Credit Reporting? Then, have separate procedures for each? Am I missing a any actual policy that would require board approval?

Dolly: Unless they are already covered under other sections of your list, you might want to also include Affiliate Sharing, Affiliate Marketing and Notice to Home Loan Applicant/Credit Score disclosures.

Good point Ted. I failed to mention that I have a procedure section for the Credit Score Disclosure. I reference sharing under the FCRA in our Privacy Policy & Procedures.

From ChexSystems:
Tips to Comply with FACTA Accuracy and Integrity of Data Reported to CRAs
Are you ready for the FACTA Accuracy and Integrity of Data Reported to Consumer Reporting Agencies? Section 312 of the Fair and Accurate Credit Transaction Act (FACTA) becomes effective on July 1, 2010. To help you prepare, FIS recommends:
1. Please read the ChexSystems, Inc. (Chex) Data Contribution Policy (DCP) that defines the requirements for furnishing data to ChexSystems, a Consumer Reporting Agency (CRA

Other than references made to this on webinar advertisements, I'm not seeing anything in the guidance that specifies what the "required data audit and testing techniques" are under FCRA and FACTA 312. The ads lead me to believe there are very specific steps to be included....any insight, anyone? Thanks.

Where can i find Appendix E? I'm used to using BOL to look at regulations, and i don't see Appendix E.

Do we need a board approved policy statement or can this be rolled into a existing policy, with "robust" procedures, of course?

http://www.bankersonline.com/regs/222/e222.html

raitch....you can find this and the rest of the FCRA & FACT Act amendments under Reg V in Alphabet Soup.

Dani...thanks.....i was having a major brain cramp.

Just so everyone knows, I used the FACT Act Policy on BOL and our auditor said we needed to enhance the integrity and accuracy of information provided to credit reporting agencies as outlined in Regulation V Section 222.42. So everyone that used the section under Responsibility of Furnishers of Credit Informtion may want to review their policy again.